### U.S. ENVIRONMENTAL PROTECTION AGENCY A 

# /

.34 ' N°b"° in the Premanufacture Notice

. 

### p. 1 FormApproved. O

.M .B . No. 2070-0012. Approval Expires 10-31-96. 

## AGENCY USE ONLY 

# Company Sanitized

GENERAL INSTRUCTIONS 

# C You must provide all information requested in this formto the extent that it is known to or reasonably ascertainable by you . Make reasonable estimates ifyou do not have actual data. Before you complete this form, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available fromthe Toxic Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-554-5603). Ifa user fee has been remitted for this notice (40CFR700 .45), indicate in the boxes above the TS-user fee identification number you have generated . Remember, your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, HQAccounting Operations Branch (PM-226), P .O . 360399M, Pittsburgh, PA 15251-6399, Arm . TSCA User fee

. Part I -GENERAL INFORMATION You must provide the currently correct Chemical Abstracts (CA) Name of the new chemical substance, even ifyou claimthe identity as confidential . You may authorize another person to submit chemical identity information for you, but your submissionwill not be complete and the review will not begin until EPA receives this information. A letter in support ofyour submission should reference your TS user fee identification number. You must submit an original and two copies of this notice including all test data. Ifyou claimed any information as confidential, a single sanitized copy must also be submitted. Part II-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE If there are several manufacture, processing, or use operations to be described in Part II . sections A and B ofthis notice, reproduce the sections as needed. Part III- LIST OF ATTACHMENTS Attach additional sheets if there is not enough space to answer a question fully. Label each continuation sheet with the corresponding section heading. In Part Ill, list these attachments, any test data or other data and any optional information included in the notice. TEST DATAANDOTHERDATA Youare required to submit all test data in your possession or control and to provide a description ofall other data known to or reasonably ascertainable by you, ifthese data are related to the health and environmental effects on the manufacture, processing, distribution in commerce, use, or disposal of the new chemical substance. Standard literature citations may be submitted for data in the open scientific literature. Complete test data (written in EnQlish), not summaries ofdata, must be submitted ifthey do not appear in the open literature. Youshould clearly identify whether test data is on the substance or on an analog. Also, the chemical composition ofthe tested material should be characterized. Following are examples oftest data and other data. Data should be submitted according to the requirements of§720

.50ofthe Premanufacture Notification Rule (40CFRPart 720) .

Test Data (Check Below any included in this notice) Environmental fate data 0 Yes " Other data ® Yes " Health effects data ® Yes Risk assessments Environmental effects data 0 Yes Structure/activity relationships OPTIONAL INFORMATION You may include any information that you want EPA to consider in evaluating the new substance. On page 1 I ofthis form, space has been provided for you to described pollution prevention and recycling information you may have regarding the new substance. So-called "binding" boxes are included throughout this formfor you to indicate your willingness to be bound to certain statements you make in this section, such as use, production volume, protective equipment . . This option is intended to reduce delays that routinely accompany the development of consent orders or Significant NewUse Rules. Except in the case of exemption applications (such as TMEA, LVE, LOREX) where certain information provided in such notification is binding on the submitter when the Agency approves the exemption application, checking a binding box in this notice does not by itself prohibit the submitter from later deviating fromthe information (except chemical identity) reported in the form . CONFIDENTIALITY CLAIMS You may claimany information in this notice as confidential . To assert a claimon the form, mark (X) the confidential box next to the information that you claimas confidential . To assert a claimin an attachment. circle or bracket the information you claimas confidential . Ifyou claiminformation in the notices as confidential you must also provide a sanitized version of the notice. (including attachments) . For additional instructions on claiming information as confidential, read the Instructions Manual . ® Mark (x) if any information in this notice is claimed as confidential . PhysicaVChemical Properties' ® Yes Test data not in the possession or control of the submitter ' A physical and chemical properties worksheet is located on the last page ofthis form . TYPE OF NOTICE (Check Only One)

® 

# 0 0 PMN (Premanufacture Notice)

INTERMEDIATE PMN (submitted in sequence with final product PMN) SNUN (Significant New Use Notice) TMEA (Test Marketing Exemption Application) LVE (Low

Volume Exemption) (r~ 40 CFR 723.50(c)(1) LOREX (LowRelease! Low Exposure Exemption) (N, 40 CFR 723.50(c)(2) LVE Modification IS THIS A CONSOLIDATED PMN? 

# a

0 LOREX Modification

Yes # ofchemicals (Prenotice Communication # required, enter # on page 3)



# 5it~i7~ PREMANUFACTURE NOTICE

EPA FORM

7710-25 (Rev. 5-95) Replaces previous editions of EPAForm7710-25.

### p. 2 Public reporting burden for this collection of information is estimated to average 1 10 hours per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or any other aspect ofthis collection of infonnation, including suggestions for reducing this burden, to Chief, Information Policy Branch, PM-223, U.S. Environmental Protection Agency, 401 M . St ., S.W

., Washington, D.C. 

### 20460 ; and to the Office of Management and Budget, Paperwork Reduction Act (2070-0012), Washington, D .C. 20503 . 

## CERTIFICATION I certify that to the best of my knowledge and belief: 1 . The company named in Part 1, sectionA, subsection 1 a ofthis notice formintends to manufacture or import for a commercial purpose, other than in small quantities solely for research and development, the substance identified in Part I, Section B

. 2 . All information provided in this notice is complete and truthful as ofthe date of submission. 3. 1 am

submitting with this notice all test data in my possession or control and a description of all other data known to or reasonably ascertainable by me as required by §720.50of the Premanufacture Notification Rule. Additional Certification Statements: If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNLTN, checkthe following user feecertification statement that applies: The Company named in Part I, Section Ahas remitted the fee of $2500specified in 40 CFR700 .45(b), or ® The Company named in Part I, Section Ahas remitted the fee of $1000 for an Intermediate PMN(defined @ 40 CFR 700 .43) in accordance with 40 CFR700 .45(b), or 0The Company named in Part I Section Ais a small business concern under 40 CFR700 .43 and has remitted a fee of$100 in accordance with 40 CFR700 .45(b) . If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR723.50(c)(1) or a Low release and low exposure exemption (LoRex) application in accordance with 40 CFR723.50(c)(2), check the following certification statements:

~ The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial purposes, other than in small quantities solely for research and development, under the terms of40 CFR723.50. 0 The manufacturer is familiar with the terms of this section and will comply with those terms; and F1 The new

chemical substance for whichthe notice is submitted meets all applicable exemption conditions. 0Ifthis application is for an LVE in accordance with 40 CFR 723.50(c)(1), the manufacturer intends to commence manufacture ofthe exempted substance for commercial purposes within 1 year of the date of the expiration ofthe 30 day reviewperiod. The accuracy of the statements you make in this notice should reflect your best prediction of the anticipated facts regarding thechemical substance described herein. An knowing and willful misinter pretation is subject to criminal penalty pursuant to 18 USC 1001 . Confidential Signature and title of Authorized Official (Original Signature Required) Date 

### X Signature of agent -(if applicable) Date

EPA FORM7710-25 (Rev. 5-95) Page 2

### p. 3 Part I -- GENERAL INFORMATION Section A-- SUBMITTER IDENTI FICATION 1 a. Person Name ofauthorized official Position Submitting Notice (in U

.S.) Company Mailing address (number and street) City, State, ZIPCode b. Agent (if Name ofauthorized official Position applicable) Company

Mailing address (number and street) City, State, ZIPCode Telephone Area Code Number

c. Ifyou are submitting this notice as part ofa joint submission, mark (X) this box. Joint Submitter (if Name ofauthorized official Position applicable) Company

Mailing address (number and street) City, State, ZIP Code Telephone Area Code Number 2 . Technical Name ofauthorized official Position Contact (in U.S.) Company

Mailing address (number and street) City, State, ZIP Code Telephone Area Code Number

3. Ifyou have had a prenotice communication (PC) concerning this notice and EPA assigned a PC Number to the notice, enter the number . Mark (X) - 

# F-1 x if none 4 . Ifyou previously submitted an exemption application for the chemical substance covered by this notice, enter the exemption number assigned by Mark (X) - 

# F] x EPA . Ifyou previously submitted a PMNfor this substance enter the if none PMN number assigned by EPA (i .e. withdrawn or incomplete) .--0 5. Ifyou have submitted a notice of Bona fide intent to manufacture or import for the chemical substance covered by this notice, enter the notice number Mark (X) - El X assigned by EPA. - if none 1 . E] Manufacture 2 . ~ Import 6 . Type of Notice - Mark (X) Only Only 3 . ® Both Binding Option E] Binding Option Mark (X) Mark (X) Mark Qthe "Confidential" box next to an subsection you claimas confidential Confidential

EPAFORM

7710-25 (Rev. 5-95) Page 3

### p. 4 Part I -- GENERAL INFORMATION-- Continued Section B -- CHEMICAL IDENTITY INFORMATION : You must provide a currently correct Chemical Abstracts (CA) name of the substance based on the ninthCollective Index (9CI) of CA nomenclature rules and conventions. Mark (X) the "Confidential" box next to an itemyou claimas confidential Complete either item1 (Class 1 or 2 substances) or 2 (Polymers) as appropriate. Complete all other items. If another person will submit chemical identity information for you (for either Item 1 or2), mark (X) the box at the right . ConfiIdentify the name, com p any, and address of that p erson in a continuation sheet. El dential 1 . Class 1 or 2chemical substances (for definitions ofclass 1 and class 2substances, see the Instructions Manual) a. Class ofsubstance - Mark (X) 1 E] Class l or 2 0 Class 2 b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances. For Class l substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CA Preferred Name must be provided, which ever is appropriate based on CA 9CI nomenclature rules and conventions) .

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice: (check one) . ® Method t (CAS Inventory Expert Service - a copy ofthe Identification ~ Method 2 (Other Source) report obtained fromthe CAS Inventory Expert Services must be submitted as an attachment to this notice) d. Molecular formula and CAS Registry Number (ifa number already exists for the substance) 

### X CAS# 

### X e. For a class 1 substance, provide a complete and correct chemical structure diagram . For a class 2 substance - (1) List the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process. (3) Indicate the range of composition and the typical composition (where appropriate) . (4) Provide a correct representative or partial chemical structure diagram . as comnlete as can be known. ifone can be reasonablv ascertained .



# See Pages 4A and 4B

® Mark (X) this box ifyou attach a continuation sheet.

EPA FORM

7710-25 (Rev. 5-95) Page 4

# Synthesis of PMNSubstance

# Inventory Expert Service

A division of the American Chemical Society Phone :800-631-1884, 614-447-3870

Fax: 614-447-3747 E-mail : answers@cas.org Web: www

.cas.org/products/client/

INVENTORY EXPERT SERVICE REPORT

Please print the above CA Index Name on the appropriate page of your PHN.

If this box is checked, CAS has made correction(s) marked in red to your IES order . Please make the same correction(s) to your PNIIJ before submitting it to the EPA.



### Page 4R

### p. 7 Part I -- GENERAL INFORMATION-- Continued Section B-- CHEMICAL IDENTITY INFORMATION-- Continued 2. Polymers (For a definition of polymer, see the Instructions Manual .) Confidential a . Indicate the number-average weight of the lowest molecular weight composition ofthe polymer you intend to manufacture. Indicate maximum

weight percent of lowmolecular weight species (not including residual monomers, reactants, or solvents) below500and below1,000 absolute molecular weight ofthat composition. Describe the methods of measurement or the basis for your estimates: GPC ~ Other [j (Specify)

i) lowest number average molecular weight: ii) maximum

weight %

below500molecular weight : iii) maximum

weight %

below1000 molecular weight : Mark (X) this box ifyouattach a continuation sheet. b. You must make separate confidentiality claims for monomeror other reactant identity, composition information, and residual information. Mark (X) the "Confidential" box next to any itemyou claim as confidential (1) - Provide the specific chemical name and CAS Registry Number (ifa number exists) of each monomer or other reactant used in the manufacture of

the polymer. (2) - Mark (X) this column if entry in column (1) is confidential . (3) - Indicate the typical weight percent ofeach monomer or other reactant in the polymer. (4) - Mark (X) the identity column ifyouwant a monomer or other reactant used at two weight percent or less to be listed as part ofthe polymer

description on theTSCAChemical Substance Inventory . (5) - Mark (X) this column if entries in columns (3) and (4) are confidential . (6) - Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured for commercial purposes. (7) - Mark (X) this column ifentry in column (6) is confidential . Monomer or other reactant and CAS Registry Number Confi- Typical Identity Confi- Maximum Confidential composition Mark (X dential residual dential (1) (2) (3) 4) 5) (6) 7)

% %

% % % % Mark (X) this box ifyouattach a continuation sheet. c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice (check one) .

Method 1 (CAS Inventory Expert Service - a copy of the identification report ~ Method 2(other source) obtained fromCAS Inventory Expert Service must be submitted as as attachment to this notice) d. Thecurrently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar polymers.

e. Provide a correct representative or partial chemical structure diagram, as complete as can be known, ifone can be reasonably ascertained.

~ Mark (X) this box ifyouattach a continutation sheet. EPAFORM

7710-25 (Rev. 5-95) Page 5

### p. 8 

## Part I -- GENERAL INFORMATION-- Continued Section B -- CHEMICAL IDENTITY INFORMATION - Continued 3. Impurities (a) - Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purpose.

CAS Registry Number if available. Ifthere are unidentified impurities, enter "unidentified." (b) - Estimatethe maximum wei ght %

of each im

purity. Ifthere are unidentified im purities, estimate their total wei ght % . Provide the Impurity and CAS Registry Number

(a) Maximum percent (b) Confidential 

### % X % %

% % % % Mark (X) this box ifyouattach a continuation sheet. 4 . Synonyms - Enter any chemical synonyms for the new chemical identified in subsection 1 or 2 . Confidential Mark (X) this box ifyou attach a continuation sheet. x

5. Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2.

Mark (X) this box ifyouattach a continuation sheet. X

6 . Generic chemical name - If you claimchemical identify as confidential, you must provide a generic name for your substance that reveals the specific chemical identity of the new chemical substance to the maximum extent possible. Refer to the TSCA Chemical Substance Inventory, 1985 Edition, Appendix Bfor guidance on developing generic names. Vinylsilane ester

Mark (X) this box ifyouattach a continuation sheet. 7. Byproducts - Describe any byproducts resulting from the manufacture, processing, use, or disposal of the new chemical substance

. Provide the CAS Registry Number ifavailable. Byproduct (1) CAS Registry Number (2) Confidential 

## X X

Mark (X) this box ifyouattach a continuation sheet. EPA FORM

7710-25 (Rev. 5-95) Page 6

### p. 9 

## Part I -- GENERAL INFORMATION-- Continued Section C -- PRODUCTION, IMPORT, ANDUSE INFORMATION : Mark (X) the "Confidential" box next to any itemyou claimas confidential . 1 . Production volume -- Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum production volume for any consecutive 12-month period during the first three years of production. Estimates should be on 100%newchemical substance basis. For a Low Volume Exemption application, ifyou choose to have your notice reviewed at a lower production volume than 10,000 k /yr, sp

ecif y the volume and mark (x) in the binding box. If ranted, you are bound to this volume 

### Maximum

first 12-month production (kg/yr) Maximum12-month production (kg/yr) Confi- Binding (100%new

chemical substance basis) (100%new chemical substance basis) dential Option Mark (x) 

### X 2 . Use Information -- You must make separate confidentiality claims for the description of the category of use, the percent of production volume devoted to each category, the fonnulation of the new substance, and other use infonnation. Mark (X) the "Confidential" Box next to any item you claimas confidential . a. (1) -- Describe each intended category of use of the newchemical substance by function and application. . (2) -- Mark (X) this column if entry column (1) is confidential business information (CBI) . (3) -- Indicate your willingness to have the information provided in column (1) binding. (4) -- Estimate the percent oftotal production for the first three years devoted to each category of use . (5) -- Mark (X) this column if entry in column (4) is confidential business information (CBI) . (6) -- Estimate the percent ofthe new substance as fonnulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for commercial purposes at sites under your control associated with each category of use. (7) -- Mark (X) this column if entry in column (6) is confidential business information (CBI) . (8) -- Indicate %

of product volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate your willingness to have the use type provided in (8) binding. (9) -- Mark (X) this column if entry(ies) in column (8) is (are) confidential business information (CBI) . Category of use (1) CBI Binding Produc- CBI % in CBI % of substance expected per use CBI Option tion % Form- (8) (by function and application i .e. a dispersive dye "tuk (x) ulation Site- Con-* Indus- Com- Binding forfinishing p

olyesterfibers) (2) (3) (4) (5) (6) (7) limited sumer trial mercial O ption (9) 

### X X X X o~ o~ % % o~ o~

o~ o~

o~ o~

o~ o~ % % * If you have identified a "consumer" use, please provide on a continuation sheet a detailed description ofthe use(s) of this chemical substance in consumer products. In addition include estimates ofthe concentration ofthe new chemical substance as expected in consumer products and describe the chemical reactions by which this substance loses its identity in the consumer product. E]Mark (X) this box ifyou attach a continuation sheet. b. Generic If you claim any category of use description in subsection 2a as confidential, entera generic description ofthat category. Read the use Instructions Manual for examples ofgeneric use descriptions. 

### description Processing Additive Intermediate

Mark (X) this box ifyouattach a continuation sheet. 3 . Hazard Information -- Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other Binding information which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices ~k (x) for the safe handing, transport, use, or disposal of the new substance. List in part III hazard information you include. ® Mark (X) this box ifyouattach hazard infonnation.

EPA FORM

7710-25 (Rev. 5-95) Page 7

### p. 10 

## Part II-- HUMANEXPOSURE AND ENVIRONMENTAL RELEASE Section A-- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any itemyou claimas confidential Complete section Afor each type of manufacture, processing, or use operation involving the newchemical substance at industrial sites you control . Importers do not have to complete this section for operations outside the U.S. ; however, you may still have reporting requirements if there are further industrial processing or use operations after im p ort . You must describe these op erations. See instructions manual 1 . Operation description Confia. Identity -- Enter the identity of the site at which the operation will occur. dential

Name 

# X Site address (number and street) City, County, State, ZIPcode If the same operation will occur at more than one site, enter the number of sites. Identify the additional sites on a continuation sheet, and if any of the sites have significantly different production rates or operations, include all the information requested in this section for those sites as attachments.

Mark (X) this box ifyouattach a continuation sheet. b. Type -- Mark (X) E:]Manufacturing ElProcessing E]Use c. Amount and Duration -- Complete t or 2 as appropriate Maximum

kg/batch 0oo^o ne<, cbemicai Hours/batch Batches/year substance) 1 . Batch Maximum kg/batch (iooi newchemical Hours/batch Batches/year 

# X substance) 2. Continuous d . Process description EJ Mark (X) to indicate your willingness to have your process description binding . (1) Diagram

the major unit operation steps and chemical conversions. Include interimstorage and transport containers (specify- e .g. 5 gallon pails, 55 gallon drum, rail car, tank truck, etc.) . (2) Provide the identity , the approximate weight (by kg/day or kg/batch on a 100%new chemical substance basis), and entry point of all starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily or per batch.) . , (3) Identify by numberthe points of release, including small or intermittent releases, to the environment ofthe new chemical substance. 

# See Page 8A

® Mark (X) this box ifyouattach a continuation sheet. EPA FORM

7710-25 (Rev. 5-95) Page 8

### C~

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### p. 12



## Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued Section A-- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER-- Continued 2. Occupational Exposure - You must make separate confidentiality claims for the description of worker activity, physical formof the newchemical substance, number ofworks exposed, and duration ofactivity. Mark (X) the "Confidential" box next to any itemyou claim as confidential . (1) -- Describe the activities (i .e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. (2) -- Mark (X) this column ifentry in column (1) is confidential business information (CBI) . (3) -- Describe any protective equipment and engineering controls used to protect workers. (4) and (6) -- Indicate your willingness to have the information provided in column (3) or (5) binding. (5) -- Indicate the physical form(s) ofthe new chemical substance (e.g., solid : crystal, granule, powder, ordust) and % new chemical substance (ifpart ofa mixture) at the tune of exposure. (7) --Mark (X) this column if entry in column (5) is confidential business information (CBI) . (8) -- Estimate the maximum number ofworkers involved in each activity forall sites combined. (9) --Mark (X) this column if entry in column (8) is confidential business information (CBI) . (10) and (11) --Estimate the maximum duration ofthe activity for anyworker in hours per day and days per year . (12) -- Mark (X) this column if entries in columns (10) and (11) are confidential business information (CBI). Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI #of CBt Maximu m duration CBI (i .e., bag dumping, filling drums) Engineering Controls option and % new Option workers Hrs/day Days/yr Mark (x) substance Mark tx) Exposed (1) (2) (3) (4) (5) (6) (7) (8) (9) (l0) (11) (12)



### X gloves, goggles, X X X nrot . r;lothina. vPnt . 

### X gloves, goggles, X X X nrot . dothinn_ vPnt . 

### X gloves, goggles, X X X nrot . dothinn. vent . 

### X gloves, goggles, X X X nrot . dothina. vent 

### X gloves, goggles, X X X nrot . dothina. vent

~ Mark (X) this box if you attach a continuation sheet. 3. Environmental Release and Disposal -- You must make separate confidentiality claims for the release number and the amount ofthe new chemical substance released and other release and disposal infonnation. Mark (X) the "Confidential" box next to each itemyou claim as confidential . (1) -- Enter the number of each release point identified in the process description, part II, section A, subsection id(3) . (2) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch) . (3) -- Mark (X) this column ifentries in columns (1) and (2) are confidential business information (CBI) . (4) -- Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify)) to which the new

substancewill be released fromthat release point. (5) --a. Describe control technology, if any, and control efficiency that will be used to limit the release of the new substance to the environment . For releases disposed ofon land, characterize the disposal method and state whether it is approved for disposal of RCRAhazardous waste . On a continuation sheet, for each site describe any additional disposal methods that will be used andwhether the waste is subject to secondary or tertiary on-site treatment . b. Estimate the amount released to the environment after control technology (in kg/day) . (6) -- Mark (X) this column if entries in columns (4) and (5) are confidential business information (CBI) . (7) -- Identify the destination(s) ofreleases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers ofthe POTW (Publicl OwnedTreatment Works) . Mark (X) ifthe POTW name or NPDES #is confidential business information (CBI) . Release Amount of new substance CBI Media of Control technology and efficiency (you maywish to optionally attach efficiency data) CBI Number released release (1) (2a) (26) e.g. s,aek nv Binding (3) (4) (Sa) Mark (x) (5b) (6) 

### 1 X X 2 X X 3 X X 4 X X

(7) Mark (X) the F POTW provide name(s) below : CBI ~ Navigable ~ Other - Specify provide NPDES # CBI destination(s) of waterway X releases to water. Mark (X) this box ifyou attach a continuation sheet. EPA FORM

7710-25 (Rev. 5-95) Page 9

### p. 13



## Part II-- HUMANEXPOSURE AND ENVIRONMENTAL RELEASE -- Continued Section B-- INDUSTRIAL SITES CONTROLLED BY OTHERS Complete section B for typical processing oruse operations involving the newchemical substance at sites you do not control . Importers do not have to complete this section for operations outside the U .S. ; however, you must report any processing or use activities after import . See the Instructions Manual . Complete a separate section B

for each type ofprocessing, or use operation involving the new chemical substance. Ifthe same operation is per-formed at more than onesite describe the typical operation common to these sites. Identify additional sites on a continuation sheet . 1 . Operation Description -- To claiminformation in this section as confidential, circle or bracket the specific information that you claimas confidential . (1) -- Diagram

the major unit operation steps and chemical conversions, including interimstorage and transport containers (specify - e .g. 5 gallon pails, 55 gallon drums, rail cars, tank trucks, etc) . On the diagram, identify by letter and briefly describe each worker activity. (2) -- Provide the identity, the approximate weight (by kg/day or kg/batch, on an 100%new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch) . (3) -- Identify by number the points ofrelease, including small or intermittent releases, to the environment ofthe new chemical substance

. (4) Please enter the # ofsites (remember to identify the locations of these sites on a continuation sheet) : # of sites



# See Page 10,04

® Mark (X) this box ifyouattach a continuation sheet. 2 . Worker Exposure/Environmental Release (1) -- Fromthe diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. (2) -- Estimate the number of workers exposed for all sites combined. (4) -- Estimate the typical duration of exposure per worker in (a) hours per day and (b) days per year. (6) -- Describe physical formofexposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, ifany, used to protect workers. (7) -- Estimate the percent of the new substance as formulated when packaged or used as a final product. (9) -- Fromthe process diagram above, enter the number of each release point. Complete 9-13 for each release point identified. (10) -- Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kg/batch) . (12) -- Describe media ofrelease i .e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify) and control technology, ifany, that will be used to limit the release of the new substance to the environment . (14) -- Identify byproducts which may result fromthe operation. (3), (5), (8), (11), (l3) and (15) -- Mark (X) this column ifan ofthe proceeding entries are confidential business information (CBI). Letter # of CBI Duration CBI Protective Equip. / %in CBI Release Amount of CBI Media of Release CBI of Workers of Engineering Controls/ Form- Number New & Control Act- Exposed Exposure Physical Formand % ulation Substance Technology ivity newsubstance Released (1) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (10a) (lOb) (II) (12) (13) 

### A X X gloves, goggles, prot. 100 X 1 X X clothing, ventilation

(14) -- Byproducts : (15) E] Mark (X) this box ifyouattach a continuation sheet, EPAFORM

7710-25 (Rev. 5-95) Page 10

## u

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### p. 15



# OPTIONAL POLLUTION PREVENTION INFORMATION To claiminformation in this section as confidential circle or bracket the specific information that youclaimas confidential . 

## In this section you mayprovide information not reported elsewhere in this formregarding your efforts to reduce or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal of the PMNsubstance. Please include new information pertinent to pollution prevention, including source 

## reduction, recycling activities and safer processes or products available due to the new chemical substance. Source reduction includes the reduction in the amount or toxicity ofchemical wastes by technological modification, process and procedure modification, product reformulation, raw materials substitution, and/or inventory control . Recyclingrefers to the reclamation of useful chemical components from wastes that would otherwise be treated or released as air emissions or water discharges, or land disposal . Descriptions of pollution prevention, source reduction and recycling should emphasize potential risk reduction subsequent to compliance with existing regulatory requirements and can be either quantitative or qualitative. The EPAis interested in the information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting of risks to other environmental media or non-environmental areas (e.g., occupational or consumer exposure) . In addition, information on the relative cost or performance characteristics of the PMNsubstance to potential alternatives may be provided. All information provided in this section will be taken into consideration during the review of this substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and exam ples. Describe the expected net benefits, such as (1) an overall reduction in risk to human health or the environment; (2) a reduction in the volume manufactured; (3) a reduction in the generation of waste materials through recycling, source reduction or other means; (4) a reduction in potential toxicity or human exposure and/or environmental release; (5) an increase in product performance, a decrease in the cost of production and/or improved operation efficiency of the new chemical substance in comparison to existing chemical substances used in similar application; or (6) the extent to whichthe new chemical substance may be a substitute for an existing substance that poses a greater overall risk to humanhealth or the environment.

I El Mark (X) this box ifyou attach a continuation sheet.

EPA FORM

7710-25 (Rev. 5-95) Page 1 l

### p. 16 

# Part III -- LIST OF ATTACHMENTS Attach continuation sheets for sections of the formand test data and other data (including physical/chemical properties and structure/activity infonnation), and optional information after this page. Clearly identify the attachment and the section of the formto which it relates, ifappropriate. Number consecutively the pages of the attachments. In the column below, enter the inclusive page numbers of each attachment . Mark (X) the "Confidential" box next to any attachment name you claimas confidential . Read the Instructions Manual for guidance on how to claim any information in an attachment as confidential . You must include with the sanitized copy of the notice form a sanitized version of any attachment i n which you claiminformation as confidential . Attachment name Attachment page number(s) Confidential 

### Material Safety Data Sheet (MSDS)

F] Mark (X) this box ifyouattach a continuation sheet. Enterthe attachment name and number . 

### A1--A8 X X X X

EPA FORM

7710-25 (Rev. 5-95) Page 12

### p. 17 PHYSICAL ANDCHEMICAL PROPERTIES WORKSHEET To assist EPA's reviewofphysical and chemical properties data, please complete the following worksheet for data you provide and include it in the notice. Identify the property measured, the page of the notice on which the property appears, the value ofthe property, the units in which the property is measured (as necessary), and whether or not the property is claimed as confidential . The physical state ofthe neat substance should be provided. These measured properties should be for the neat (100%pure) chemical substance. Properties that are measured formixtures or formulations should be so noted (%PMN substance in -) . You are not required to submit this worksheet; however, EPAstrongly recommends that you do so, as it will simplify review and ensure that confidential information is properly protected. Youshould submit this worksheet as a supplement to your submission oftest data. This worksheet is not a substitute for submission oftest data. Property Mark Page Value Measured o Confi- (X) if provided number Estimate dential Mark(X) (a) (b) (c) (M or E) (d) 

### X A4 X Physical state of neat substance (s) (1)- (g) X A4 X Vapor pressure Temperature °C Torr X A4 X Density/relative density g/cm3 X Solubility @ Temperature °C Solvent g/L X A4 X Solubility in water Temperature °C g/L X A4 X Melting temperature °C X A4 X Boiling / sublimation temperature torr pressure °C X X Spectra Dissociation constant Particle size distribution Octanol / water partition coefficient Henry's Law

constant X Volitalization from

water Volitalization from

soil X pH@concentration X Flammability Explodability Adsorption / coefficient Other - Specify

I

EPAFORM

7710-25 (Rev. 5-95) Page 13

### p. 18 

# i MATERIAL SAFETY DATA SHEET Revision: 1 .0 05/11/2005 Page: 1 of 8 

# 1 . PRODUCT AND COMPANY IDENTIFICATION Product name: Chemical name: Supplier : Contact numbers: 

# 2. COMPOSITION I INFORMATION ON INGREDIENTS COMPONENT CAS# CONCENTRATION



# I See Section 15 for chemicals appearing on Federal or State Right-To-Know lists. 

# 3. HAZARDS IDENTIFICATION EMERGENCY OVERVIEW WARNING! CAUSES EYE IRRITATION. MAY CAUSE SKIN IRRITATION. MAY CAUSE IRRITATION OF THE RESPIRATORY TRACT. 

# 4. FIRST AID MEASURES Swallowing If patient is fully conscious, give two glasses of water. Induce vomiting. Obtain medical attention. Skin Remove contaminated clothing. Wash skin %ti ith soap and water. If irritation persists or if contact has been prolonged, obtain medical attention. Attachment Page A1

### P. 19 

# MATERIAL SAFETY DATA SHEET Revision : 1 .0 05/11/2005 Page: 2 of 8 Inhalation Remove to fresh air. Obtain medical attention if symptoms persist. Eye contact Immediately flush eyes with water and continue washing forseveral minutes. Obtain medical attention if discomfort persists.



# 5. FIRE-FIGHTING MEASURES Flash point : Flammable limits Lower limit: Not available Upper limit: Not available Special protective equipment for firefighters Use self-contained breathing apparatus when fighting fires in enclosed areas. Extinguishing media Suitable: Large fires:

- alcohol-type foamor universal-type foams Small fires : - C02 - dry chemical Unusual fire and explosion hazards None 

# 6 . ACCIDENTAL RELEASE MEASURES Personal precautions Wear suitable protective equipment. Environmental precautions Prevent runoff.

Attachment 1'aQP A?

### p. 20 

# MATERIAL SAFETY DATA SHEET Revision: 1 .0 05/11/2005 Page: 3 of 8 Methods for cleaning up Cover with absorbent or contain. Collect for disposal . Observe government regulations. 

# 7. HANDLING AND STORAGE HANDLING Handling precautions Avoid contact with eyes, skin and clothing. Avoid breathing vapor. Wash thoroughly after handling. STORAGE Storage requirements Keep container closed. 

# 8 . EXPOSURE CONTROLS I PERSONAL PROTECTION PERSONAL PROTECTION Respiratory protection Self-contained breathing apparatus in high vapor concentrations. Hand protection / protective gloves Recommended order of use: 4H Butyl Neoprene Nitrile (NBR) PVC-coated Eyeprotection Monogoggles Other protective equipment Eye bath Safety shower 

### ENGINEERING CONTROLS Ventilation General (mechanical) roomventilation is expected to be satisfactory where this product is stored and handled in closed equipment. Special, local %entilation is needed at points N%here %apors can be expected to escape to the workplace air. 

## EXPOSURE LIMITS

Attachment PraKa A3

### p. 21 

# MATERIAL SAFETY DATA SHEET Revision: 1 .0 05/11/2005 Page: 4 of 8 

# 9. PHYSICAL AND CHEMICAL PROPERTIES APPEARANCE Physical state Color Odor 

### OTHER PROPERTIES Boiling point Melting point pH Specific gravity (H20=1) Vapor pressure Vapor density (sir=1) Solubility in water Evaporation rate (Butyl Acetate=1) Flash point Upper explosion limits Lower explosion limits Molecular weight 

# 10. STABILITYAND REACTIVITY Stability: Stable. Stability - Conditions to avoid None known. Incompatible materials Acids. Bases. Strong oxidizing agents. 

### Att,qchment Page A4

### p. 22 

# I

MATERIAL SAFETY DATA SHEET Revision: 1 .0 05/11/2005 Page: 5 of 8 Hazardous combustion products Burning can produce the following combustion products : Oxides ofcarbon. Oxides ofsilicon. Carbon monoxide is highly toxic if inhaled: carbon dioxide in sufficient concentrations can act as an asphyxiant. Acute overexposure to the products of combustion may result in irritation of the respiratory tract. Hazardous polymerization: Will not occur. Hazardous polymerization - Conditions to avoid None known. 

# 11 . TOXICOLOGICAL INFORMATION SWALLOWING Acute effects Maycause the following effects: - dizziness, faintness, drowsiness, decreased awareness and responsiveness, euphoria, abdominal discomfort, nausea, vomiting, staggering gait, lack of coordination and coma Effects of repeated overexposure Long-termrepeated oral _ may result in the development of progressive liver injury with fibrosis. 

### SKIN ABSORPTION Acute effects No evidence of harmful effects fromavailable information. 

### INHALATION Acute effects May cause irritation of the respiratory tract. 

### SKIN CONTACT Acute effects Maycause irritation. 

### EYECONTACT Acute effects May cause discomfort . May cause the tiollowing effects: - mild conjunctivitis - slight excess redness of the conjunctivae - tear production Injury to the cornea is not expected. 

## Medical conditions aggravated by overexposure Repeated exposure ggravate liver injury produced fromother causes. 

### Other effects of overexposure Repratcd Iii - -- - ~ has hcen ,hru n to ailNer~ek aftei t the central ncn ~~u .; ,%,tem Of tile lC " tll, . (irt~tluClnk ct ii~IIC~tli~n ~~fctlclt, %%hlLh together c,in,htutl'1 - ~ ~- ~~~-I I I7C,C Itklllile Attachment PnKe A5

### p. 23 

# MATERIAL SAFETY DATA SHEET Revision: 1 .0 05/11/2005 Page: 6 of 8 mental and physical retardation, disturbances oflearning, motor and language deficiencies, behavioral disorders, and small size head.



# 12. ECOLOGICAL INFORMATION All available ecological data have been taken into account for the development of the hazard and precautionary information contained in this Safety Data Sheet. 

# 13. DISPOSAL CONSIDERATIONS General : Incinerate in a furnace where permitted under appropriate Federal, State, and local regulations. 

# 14 . TRANSPORT INFORMATION DOT Classification This product is not regulated by DOT . Freight description road: CHEMICALS, NOIBN 

## IMDGClassification This product is not regulated by IMDG. 

## ICAOClassification This product is not regulated by ICAO . 

# 15 . REGULATORY INFORMATION Comprehensive Environmental Response Compensation and Liability Act of 1980 (CERCLA) requires notification of the National Response Center of release of quantities of hazardous substances equal to or greater than the reportable quantities (RQ's) in 40CFR302.4. Components present in this product at a level which could require reporting under the statute are: **** NONE   Superfund Amendments and Reauthorization Act of 1986 (SARA) Title III requires emergency planning based on Threshold Planning Quantities (TPQ's) and release reporting based on Reportable Quantities (RQ's) in 40CFR355 (used for SARA 302 and 304) . Components present in this product at a level which could require reporting under the statute are: ** ** N NE   O tiuperfund .krnendments and Reauthorizatinn %rt of 1986 (.S ~R.~) litle III requires submission of annual 

## SIGNIFICANT DATA WITH POSSIBLE RELEVANCE TO HUMAN HEALTH

Attachment Page Ah

### p. 24 

# MATERIAL SAFETY DATA SHEET Revision: 1 .0 05/11/2005 Page: 7 of 8 reports of release of toxic chemicals that appear in 40CFR372 (for SARA 313) . This information must be included in MSDS's that are copied and distributed for this material . Components present in this product at a level which could require reporting under the statute are: ** ** NONE   Ntassachusetts Right-To-Know Substance List (MSL)--Hazardous Substances and Extraordinarily Hazardous Substances on the MSL must be identified when present in products. Components present in this product at a level which could require reporting under the statute are: ** ** NONE   Pennsylvania Right-To-Know Hazardous Substance List--Hazardous Substances and Special Hazardous Substances on the list must be identified when present in products. Components present in this product at a level which could require reporting under the statute are: ** ** NONE   EPA Hazard Categories (SARA 311, 312) : Immediate Health Hazard California Proposition 65 This product contains no levels of listed substances, which the State of California has found to cause cancer, birth defects or other reproductive harm, which would require a warning under the statute. California SCAQMD Rule 443.1 VOC's Volatile Organic Components (VOC's) = Substances with vapor pressure of => 0 .5 mmHg at 104'C (219.2'F) . ** **NOT DETERMINED**** 

## CHEMICAL INVENTORY United States: This is a new chemical substance that is not currently on theTSCA Inventory. Under TSCA regulations, 40 CFRSection 720 .36, experimental products such as these can only be used for research and development purposes either directly by, or under the supervision ofa technically qualified person. The law furtherstipulates that an evaluator may test and evaluate samples such as these but, with few exceptions, the sample or products derived fromit may not be used for commercial purposes until the new substance is added to the TSCA Inventory via Premanufacture Notification. 

# 16 . OTHER INFORMATION HNIIS RATING Health : I Flammability I Reactivity I PPI : X LEGEND STP Standard tem perature and pressure W'W Wei hGWei ht 0 (HMIS) Minimal hazard I (HMIS) Sli ght hazard 2 (HMIS) Moderate hazard 3 (HMIS) Serious hazard -I (HMIS) Severe hazard L X 11IMISt Personal protection rating to he supplied by user depending tin use conditions 

### Attachment Page A7

### p. 25 

# MATERIAL SAFETY DATA SHEET Revision: 1 .0 05/11/2005 Page: 8 of 8 The opinions expressed herein are those ofqualified experts withi e believe that the information contained herein is current as ofthe date of this Safety Data Sheet. Since the se of this _information and of these opinions and the conditions of use of this product are not within the control o L----- J it is the user's obligation to determine theconditions of safe use of the products.

Attachment PnQe AH

## HEALTHEF TA TEMENT

a very low

order of acute toxicity by swallowing or skin penetration . liberated has in acidic stomach fluids may cause additional toxic effects in man following ingestion . is slightly toxic following the acute inhalation ofvapors generated at ambient temperatures is a slight skin and mild eye irritant. Repeat dose studies identify the kidney and urinary tract as primary target organs following inhalation of vapor. Repeated inhalation exposure to an aerosol of a solution of hydrol ecis not expected to cause any adverse health effects. is a mild skin sensitizer. was negative for mutagenicity in two in vitro assays. Similar findings are anticipated for

~~can torm additional k ~ upon contact with body fluids, particularly in the stomach because`of the lowstomach pH . Therefore, the potential for toxicity due to visual disturbances, digestive tract irritation, CNS depression, repro uctive and fetal toxicity, and liver kidney and heart muscle damage) to result fromaccidental in I t' f 1 6es ion o arge quantitie ot=should be recognized. Since dermal and inhalation ex os re would produce lessno contact with acidic media) the concern for toxicity fromis much lower by these routes .

Attachment Page A9 

# 0

## Acute Oral Toxicity

Whe as administered by oral gavage to rats, the acute oral LDS0 was detennined to be >5000 mg/kg, indicating a very low order of toxicity in the rat by this route. Acute Dermal Toxicity In order to determine the potential for systemic toxicity by absorption across the skin, (undiluted) was applied to the clipped dorsal skin of rats and maintained in contact for 24 hours under a semi-occlusive dressing. The acute percutaneous LDSOwas determined to be >2000 mg/kg, indicating a very low

order of toxicity in the rat by this route. Acute Inhalation Exposure When rats were exposed for 4 hours to dynamically generated vapors ok--i poor coordination, tremors, anesthesia, and death were reported. The 4-hour LC5o value was estimated to be 4500 ppm, indicating slight toxicity in the rat by this route . Repeat Dose Studies In a subchronic (90-day) vapor inhalation study o hours/day, 5 days/week) resulted in no consistent evidence for toxic effects, indicating a noobserved-adverse-effect-level (NOAEL) of greater than 50 ppm with this treatment protocol . The results fromthese repeated inhalation studies identify the kidney and urinary tract as the primary target organs following re eated inhalation exposure to concentrations less than 100 ppmbut greater than 50 ppmofas a vapor. Repeat Dose Studies on HydrolyZ Male rats were exposed to a res irable aerosol of a hydrolyzate o which is primarily the ( ~d

erived fromthe land not the same~ hemical structure~ `tTie unhydrolyzed -~ generate at roomtemperature froma 2%aqueous dispersion o ~ for 6 hours/day, 5 days/week, for a total of 19 exposures. The aerosol concentration determined to be 145 mg/m3 . There were no deaths, clinical signs of toxicity, or gross or microscopic pathology chan n the kidneys or respiratory tract associated with exposure to an aerosol of a hydrolyzate o~under these conditions. Primarv Skin Irritation To determine the primary dermal irritation potential o= 0 .5-ml neat liquid was applied to the clipped, intact skin of male and female New Zealand White rabbits and maintained under a semi-occlusive cover for 4 hours. A primary irritation index of 1 .3 was calculated from the results, consistent with a slight skin irritation potential for=in the rabbit . Primary Eye Irritation To determine the primary eye irritation potential of= 0.1-ml neat liquid was instilled into the eyes of male and female New Zealand White rabbits. A maximum average score of 4.0 was calculated at the 1-hour time point, indicating___Iwas mildly irritating to the rabbit eye under the conditions of this test.

Attachment Pn9P AI0 

## exposure of rats to 5, 15, or 50 ppm(6

## Skin Sensitization Potential

The potential for cat( produce dermal contact sensitization was assessed in a guinea pig sensitization maximization test. The design of the study consisted of an intradermal induction phase, followed by a topical induction phase and subsequent topical challenge. Irritation (degree of erythema and edema) was graded using a 0 to 3 severity scale after induction and challenge phases. Positive skin reactions were observed at the topical challenge sites in 20%of the animals. The severity of irritation scores was 0 .5 at 24 and 48 hours. The sensitization rate and severity of response indicate thatf----Iis a mild skin sensitizer . Genotoxici Studies The potential mutagenicity oq= was evaluated in the Salmonella typhimurium assay (Ames test) and in the mouse lymphoma mutagenesis test in the presence and absence of metabolic activation=was not mutagenic in either of these tests.



# C Attac}imPnt Page All

# Preliminary Risk Assessment of Intermediate PMNSubstance

Worker Exposure Assessment and End-Use ll _ s produ

ced exclusively at one o _ -- plari t( The synthesis 04 _ ill take place in a closed reactor and distillation systemlocated within a manufacturing area, partly outdoors, and partly i oors, serviced by local exhaust ventilation. Operators will obtain samples of

using a self-contained and vented sampling system . QClaboratory personnel will use exhaust hoods when preparing samples and will followanalytical methods that have been developed to maximize safety and minimize exposure.



# Jinvolved with the manufacture of are trained and exp erienced in handling hazardous materials, such as the various intermediates, and products These processes by vacuumdistillations. Therefore, the process is typical for the specified manufacturing department . The operating personnel are required to use personal protective equipment (PPE) and are trained to follow all safety recommendations as specified in the MSDS and within the Operating Instructions. The personnel protective equipment includes safety hard hat, steel-toed shoes, chemical resistant gloves, and goggles. The has moderate volatility. The PPE worn by workers will effectively eliminate the potential for dermal or inhalation exposure. The workers are trained in emergency procedures in the event of an unexpected exposure, accidental release, spill or fire. The i-~will b

e[ :=

--- -- intermediate of this process, which involve _ - molecule. T is next intermediate is known as and is described in the intermediat The~ but long te The same training, PPE, and procedures described above are used downstreamfor the~-lurocess.

Attachment Page AI?

## Environmental Release Assessment

At th _ the potential for releases o into the environment will be minimized . Based on the intended process, it is anticipated that there will be three potential releases of the intermediate PMNsubstance to the environment (see Pages 8A and 9) . The potential releases will be associated with disposing ofwaste QA samples, filter bag disposal, and waste clean-up solvent which will contain low

levels of intermediate PMNsubstance. Waste QA sample bottles containing the intermediate PMNsubstance will be collected with other wastef- --- --- Isamples in a RCRA collection site and transferred to an on-site, RCRA approved rotary kiln, permitted b The efficienc of the incineration process in destroying buckets ofsample bottles including, is estimated to be beyond 99.99% . Likewise, waste clean-up solvent be collected in a waste solvents tank and transferred by dedicated pipeline tothe kiln for incineration. Consequently, there will be effectively no releases of L-7associated with the incineration ofwaste sample bottles or equipment clean-up solvent. Used filter media such as bag filters ar collected for on-site disp osal in the RCRA-a roved landfill . The contained will underg to an[_ __)amorphous polyme

At rnchmPnt PakP A13

### GC OF INTERMEDIATE PMN SUBSTANCE

Attachment Page Al4

### Attachment Page A15